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The Interplay of Web Aggregation and Regulations


Harry Zhu, Stuart Madnick, Michael Siegel

CISL WP #02-17
November 2002

MIT Sloan School of Management

50 Memorial Drive
Cambridge, Massachusetts 02142-1347
Hongwei Zhu, Stuart E. Madnick, Michael D. Siegel
MIT Sloan School of Management
30 Wadsworth Street
Cambridge, MA 02142, USA
{mrzhu, smadnick, msiegel}

Web aggregation is a service that transparently collects
The development of web technology has led to the information from multiple web sources and performs
emergence of web aggregation, a service that collects useful analysis to add value to the integrated information
existing web data and turns them into more useful [1]. Shopbots, such as and,
information. We review the development of both are examples of comparison aggregation, which allow
comparison and relationship aggregation and discuss their users to compare prices and other attributes of products
impacts on various stakeholders. offered by multiple vendors. Relationship aggregation
allows users to manage multiple relationships using a
The aggregator’s capability of transparently extracting single logon. For example, Citigroup’s allows
web data has raised challenging issues in database and users to view all their online relationship accounts in one
privacy protection. Consequently, new regulations are place. We will discuss in detail the evolution and impact
introduced or being proposed. We analyze the of both comparison and relationship aggregation in
interactions between aggregation and related policies and section 2.
provide our insights about the implications of new
policies on the development of web aggregation. Since aggregation service involves multiple information
creators, and especially relationship aggregation deals
KEY WORDS with personal information, complicated policy issues
International IP Law, Privacy Law, Web Aggregation arise. Most of the issues hinge upon the tradeoff between
the free flow of information and the protection of
intellectual property and consumer privacy. In section 3
we will discuss these issues and analyze how emerging
1. Introduction policies may affect the development of information
aggregation. Section 4 concludes our discussion.
The development of Information Technology (IT) and the
Internet over the past decade has brought sweeping social
and economic changes to our society. Conversely, new 2. Evolution and Impact of Web Aggregation
regulations in response to emerging IT enabled services
have great impact on their effectiveness and evolution. The development of web aggregation can have great
We will examine the interplay between IT and policy impact on markets and society. In this section, we will
using the example of web aggregation. discuss the evolution and analyze the impact of
comparison and relationship aggregation.
The web has dual effects on the dissemination of
information. It allows information creators to directly 2.1 Comparison Aggregation
reach vast end users, eliminating the intermediaries
necessary in traditional media. Meanwhile, since no Finding the best offers from thousands of e-stores is not
single information creator can meet all the information an easy task even with the help of a generic search engine.
needs of a user and there are over 40 million potentially Comparison aggregators, which collect product offering
useful sources in the U.S. alone1, there is a need for information by crawling e-store sites and organize the
intermediaries to bring information from various sources collected information for easy retrieval and comparison,
to end users. This latter effect has been the major have emerged as a helpful intermediary between retailers
motivation for the emergence and the development of web and consumers. DealTime, mySimon, and bizRate are
aggregation. among the most common comparison aggregators in the
U.S. Table 1 compares them with information found at
their websites. They have similar features and often have
Number of Internet hosts in 1999 according to World Bank online data. overlap in vendor coverage.
search cost in online shopping. This results in increased
product variety and lower prices online. In addition,
Table 1. Comparison of Three Comparison Aggregators empirical research reveals that not all consumers buy
from the vendors that offer the lowest price [2, 3]. The
MySimon DealTime bizRate overall service quality, e.g., on time delivery, flexibly
URL return policy and friendly customer services, also can
U.S., France, U.S., U.K. U.S. only
Presence Germany
significantly affect consumer’s purchasing decisions.
Scope 1) 2,000 online 1) 4,000 online 1) 1,400 sellers; Comparison of these characteristics by aggregators results
stores and 32,000 stores; 2) 19 categories in increased competition beyond price. Consequently,
offline services; 2) 26 major consumers are able to enjoy improved service from online
2) 250 product categories;
categories; 3) 360 paying
vendors. These benefits, measured in consumer surplus,
3) 130 paying merchants are estimated to be nearly $1 billion in book market [4]
merchants and over $6 billion in consumer electronics market [5] in
Listing 1) Free; 1) Free; 1) Free; the U.S. Although consumers may have the risk of
Requirement 2) Merchants over 2) Merchant can pay 2) Merchant can
exposing their consumption pattern to aggregators, this
3,000 monthly leads a fee for brand pay a fee for
are required to pay a recognition premium information is often studied collectively without involving
fee and receive placement any personal data. Consumers may also have a potential
brand recognition risk of being intruded by aggressive targeted marketing
Merchant Gomez Gomez bizRate campaigns that violate consumers’ autonomy privacy.
Personali- 1) Calendar and 1) Shopping 1) Timesaving
zation links to gift advisory; features (auto form Through the service of comparison aggregators, vendors
searches; 2) Saved searches; filling, etc.); have immediate access to vast potential customers. Small
2) Saved searches; 3) Newsletter 2) Exclusive deals; but niche market players can gain consumer awareness
Newsletter 3) Newsletter
Revenue 1) Advertising; 1) Advertising; 1) Advertising;
through the listing service of aggregators. In addition,
Model 2) Fee based listing; 2) Fee based listing; 2) Fee based comparison aggregation is also a great tool for a vendor to
3) Consulting 3) Consulting listing; learn its competitors and design competitive offering
(search technology) (search technology) 3) Consulting strategies, e.g., dynamic pricing. For example,
(market and
consumer analysis) allows one to compare its price with a
number of other online booksellers and dynamically offer
There are many other comparison aggregators in the U.S., a competitive price. Overall, vendors are facing a higher
e.g., (now part of Microsoft’s MSN), level of competition. Consumers may spend less time, and Some of the visiting their sites, potentially reducing the opportunities
specialized compassion aggregators have been expanding of spontaneous selling and weakening the relationship
their aggregation categories. For example, PriceScan, an with their customers. The entire databases about various
aggregator focused on computer and electronics, has products, part of the valuable assets possessed by the
included books, sporting goods, and home & garden into online vendors, are now being freely data-mined by
its aggregation offering. aggregators and can potentially be used by competitors.

Table 2. Costs and Benefits of Comparison Aggregation Comparison aggregation is also an effective targeted
marketing channel. Manufactures and vendors can
Stakeholders Benefits Costs/Risks deliver their messages to customers who are looking for
Consumers • Convenience and lower • Possibility to be price specific products.
search cost discriminated
• Lower price • Minor risk of losing
Finally, aggregators are becoming more proficient in
• Better service autonomy privacy
Vendors • Access to vast • Increased competition
intermediation by accumulating knowledge about vendors
consumers • Less visiting time and consumers. They are enjoying multiple revenue
• Knowledge of • Weakening customer streams while expanding their service coverage in terms
competitors relationship of product categories and geographical areas. But
• Dynamic pricing • Data could be used by aggregators are still fairly new entities in the electronic
Manufacturers Effective targeted marketplace. They are still experimenting to become a
marketing channel viable business. Critical to their success is their capability
Aggregators • Establishment as • Profitability of collecting enough vendor data to offer unbiased and
intermediary • Potential impact of database relatively complete comparison information. This
• Multiple revenue protection policy contingency will be affected if access to vendor data
becomes more difficult or costly due to possible future
policy changes that advocate online database protection.
The impact of comparison aggregation on stakeholders is
summarized in Table 2. Comparison aggregation offers
2.2 Relationship Aggregation
many benefits to consumers. It significantly reduces the
Using “screen scraping” technology, an aggregator can Consumers can also save by eliminating check writing,
extract account information from different websites on mailing, and late fees.
behalf of its customers even without the cooperation of
the website owners. Financial institutions initially viewed 3. Policy Issues of Web Aggregation
aggregators as a threat to their operations and tried to
block the access by aggregators; First Union National Aggregators collect and reuse information that resides in
Bank filed a lawsuit in 1999 against PayTrust, an early the public domain or in proprietary systems. Relationship
online bill payment aggregator. Later First Union aggregators also deal with vast personal information of
withdrew litigation and published a set of guidelines for individual consumers. Their increasing capabilities and
aggregators to follow. By late 2001, over 100 financial widespread adoption have created concerns about the
institutions, including First Union, and a few web portals balance between effective use of information and
are offering account aggregation services. Financial adequate protection of information providers and
institutions have changed their view to see aggregation as consumer privacy. Some unique issues, such as
a necessary online banking service and a tool that trespassing in cyberspace, have also been brought up in a
provides many other benefits, e.g., increased customer number of lawsuits against aggregators and require
loyalty, opportunity for cross selling, and possibility to attention because they are not particularly addressed by
provide value-added/cost-reducing services such as online existing regulations. We will discuss these issues, new
bill presentment and payment. policy initiatives, and their implications to the
development of information aggregation.
Table 3. Evolution of Relationship Aggregation
3.1 Database Protection
Three Years Ago Today (2002) Future
Scope Single category, Multiple A focal point for all
e.g., financial or categories personal information An aggregator obtains its data from hundreds of
rewards needs thousands of information sources, each containing factual
Usage Emergent 1-2 million users Steadily increasing data, such as product prices or daily balances. In legal
Stakeholder 1) Aggregators 1) Aggregatees 1) Users will include terms these sources have been called collections of
Dynamics emerged as a new see aggregation as professionals who
entity with a necessity and an provide financial
information and databases interchangeably. These
aggregation opportunity planning, databases often take substantial efforts to create and
technology 2) Aggregatees management, and maintain. Therefore database owners have great
2) Aggregatees become advisory services incentives in protecting their investment.
viewed aggregators 2) Billers and
aggregators as a 3) Some early electronic payment
threat aggregators enablers will There are several possible legal mechanisms for
become participate conventional database protection, such as trade secrets,
technology aggregation contract law, and copyright [7, 8]. But on the Internet,
many databases are made available to the general public
Capability Reporting tool that 1) Limited fund 1) Full fledged
provides transfer and bill financial for free access, eliminating the possibility of trade secret
consolidated view payment management protection. Although some database owners have
and convenience capability 2) Integration with managed to negotiate licensing agreements with their
of auto login to 2) Limited comparison and other
users, it is costly and sometimes impossible to enforce
other sites availability on aggregation services
mobile devices 3) Accessible from those contracts.
any network device
Technology Screen scraping Screen scraping Standard based As to copyright protection, the U.S. Copyright Act of
and limited direct secure information 1976 and its subsequent amendments are to protect
feed using sharing
industry standards “original works of authorship”. Databases, a form of
compilation or derivative works of non-copyrightable
Table 3 summarizes some of the changes and the trend in facts, are only protected to the extent of the creative
relationship aggregation. The capability of fund transfer selection and arrangement of the data. Therefore, in the
across organizational boundaries and electronic bill current copyright protection framework, it is the
presentment and payment (EBPP) are among the most “originality”, not the effort, that is protected. This
wanted features of online banking [6]. With the principle has been clearly demonstrated in the landmark
capability of accessing all financial accounts, aggregators Supreme Court ruling of Feist Publications vs. Rural
are well positioned to provide these services. One of the Telephone Co. in 1991. Feist, a phone directory
biggest benefits of these services is cost savings for both publisher, copied Rural’s white page listings that had
billers and consumers. For billers, the transaction cost fewer than 8,000 records organized alphabetically by last
can be reduced from over $1 to 2 or 3 cents per bill2. name. The district court applied the “sweat of the brow”
doctrine and granted Rural summary judgment to reward
its effort in compiling the listings. But the Supreme Court
2 rejected the doctrine on the basis of the originality
From information presented at the American Bankers’ 2nd Annual
Account Aggregation Conference, April 23-24, 2001, Virginia, U.S.A. requirement of copyright. Rural’s white pages do not
show any originality because the selection and the Congress. Internationally, the World Intellectual
arrangement of the listings are entirely obvious. Property Organization (WIPO) has been considering an
international treaty for database protection. As an initial
In a similar vein, courts rejected copyright infringement supporter of such a treaty, U.S. quickly changed to an
claims found in a number of recent cases against opposing position soon after the withdrawal of HR 3531
aggregators, such as eBay vs. Bidder’s Edge, in 1996 [7]. It will take tremendous debate and
Ticketmaster vs., and mySimon vs. negotiations to form an acceptable framework for
Priceman. In fact, aggregators often organize the database protection worldwide. The major issue is to
extracted information and express it in their own ways, arrive at an appropriate scope of protection without the
predefined or configured by end users. Copyright risk of creating information monopolies and discouraging
infringement can hardly stand under this circumstance. downstream innovations based on existing information.

The Internet has allowed access, duplication, and We speculate that the final legislation will have little
distribution of databases with little cost. Database impact on information aggregation because in most cases
creators argue that without any effective protection their the “sweat of the brow” doctrine does not and should not
incentives of creating and maintaining those databases apply to the underlying data extracted by web
will diminish because of unfair competition from free aggregators. Product databases compiled by online
riders. The European Union first embraced the “sweat of vendors are to inform buyers and facilitate sales of
the brow” doctrine and introduced Database Directive in products, not the data. The compilation effort should be
1996, mandating member nations to implement it by accounted as part of product selling activities. The reuse
1998. This directive recognizes the need for protecting of this data by aggregators is also to inform buyers and
the investment of database owners by granting them a sui facilitate sales of products, which would enhance rather
generis (Greek word meaning “of its own kind”) right. In than corrode the initial investment of data compilation.
the U.K. implementation of the Directive, the Copyright For financial account aggregation, some of the data is the
and Rights in Databases Regulations 1997, this special result of user-initiated transactions (e.g., deposit,
right is called “database right” and is defined as a withdrawal, and fund transfer), which is effectively
“property right … in a database if there has been a entered by the user, not the financial institution. In
substantial investment in obtaining, verifying or addition, aggregation is performed with authorization
presenting the contents of the database”. A recent case from the user who arguably owns the information about
settled according to this regulation is British Horsing himself. The function of the database is very much like a
Board (BHB) vs. William Hill. Betting service provider security box in a bank (i.e., users put their personal
William Hill published on its own web site the lists of information in a secure system), accessible by an
runners for forthcoming races compiled by BHB without authorized entity on user’s behalf. In both cases the effort
its consent. On February 9, 2001, the High Court of the of compiling databases does not constitute the core
U.K. ruled that William Hill violated BHB’s database business of aggregatees. This is fundamentally different
right on the accounts that BHB had invested significant from the BHB case, where the data is the business.
amount of time and money in compiling, verifying, and
presenting the data and the portions reported by William Even if some of the aggregated data falls under the “sweat
Hill were substantial with regard to the importance, not of the brow” doctrine, we speculate that the impact of the
the amount, of the information to those interested in horse final legislation on information aggregation will be
racing3. limited for the following reasons. First, E.U. Database
Directive has been regarded as the strictest regulation for
Although the “sweat of the brow” theory has been database protection. Even so, aggregators have been
adopted throughout the E.U., it has not been successful in successfully operating in most E.U. countries, e.g., Klkoo,
the U.S. Four bills have been introduced since 1996 in PriceRunner, DealTime, mySimon, and CitiBank’s
the U.S. and all failed to pass. Pressed by the reciprocity account aggregator. Second, factual information, once
provision in the E.U. Database Directive, U.S. attempted aggregated, is hard to identify where it originally comes
a similar bill in 1996 (HR 3531, Moorhead). After its from. Given the large quantity of factual information and
failure, HR 2652 was introduced by Coble in 1997, which huge number of sources involved in aggregation,
received strong opposition from a loose coalition of enforcement is a big problem. Third, as we have seen
science groups, libraries, and the industries in telecom, from preceding discussions, database creators such as
ISPs, and valued-added database producers [7]. small online vendors often gain incredible reach to
Following the enactment of the E.U. Database Directive potential customers through aggregators. The
in 1998, two more controversial bills, HR 354 by Coble interweaving interests in sharing and reusing information
and HR 1858 by Bliley, were introduced in 1999 and no reduce, if not completely eliminate, the need for litigation.
agreement was reached by the end of the last session of Fourth, even database creators need to rely on other
sources to compile their databases. In this sense, there are
few “pure” database creators. For instance, a vendor
News release of BHB on February 9, 2001. Full text can be found at compiles its product database using information from
manufacturers. And finally, consumers and providers related relationship aggregation, privacy and security
want and need web aggregation evidenced by the concerns are the major barriers that prevent people from
compelling benefits discussed earlier. These public putting trust in the service. These issues have to be
interests should not be overlooked and regulations should addressed with technical and regulatory measures to fully
put structure that guides the exploitation of the new take advantage of information aggregation.
opportunities of web aggregation.
Privacy protection is very complex in the U.S. There are
3.2 Trespassing in Cyberspace many privacy related regulations, each having its own
context and addressing specific issues. For financial
Database owners have used another controversial theory, related privacy protection there are Right to Financial
“trespass to chattels”, to charge against online information Privacy Act, Fair Credit Reporting Act, Federal
aggregation activities. For example, eBay claimed that Educational Rights and Privacy Act, and the most recent
80,000 to 100,000 daily requests from Bidder’s Edge Title V of the Financial Services Modernization Act (also
constituted 1.53% total requests processed by eBay web known as Gram-Leach-Bliley Act, or GLBA). In addition
servers. The court issued a preliminary injunction to stop to its diverse characteristics, U.S. privacy law is also
Bidder’s Edge from aggregating information from eBay highly decentralized (having both Federal and sometimes
based on the reasoning that significant harm could be divergent State laws) and dynamically evolving [12].
caused if such activities are allowed. However, in a Since no privacy law in the U.S. is specifically designed
similar case the court rejected Ticketmaster’s trespass with the Internet in mind, it is a delicate issue in today’s
claim against because “it is hard to see how network environment. Recognizing the complexity,
entering a publicly available web site could be called a delicacy, and importance of privacy protection, over 100
trespass, since all are invited to enter”4. U.S. corporations, such as IBM, American Express, and
AT&T, have appointed their Chief Privacy Officers
Legal experts have strongly opposed the application of (CPOs) since 1998 to oversee privacy issues5.
trespass theory to the Internet. In a friend-of-the-court
brief regarding the eBay vs. Bidder’s Edge case, 28 law The GLBA is one of the recent regulations that are most
professors pointed out that it is inappropriate to substitute closely related to information aggregation, especially
possible future harm for the actual harm required by the financial account aggregation. Title V of the Act is
law of trespass to chattels. They concluded that he ruling dedicated to financial privacy protection, demanding all
threatens efficient information exchange on the Internet financial institutions to inform their customers about their
and the public interests demand a reversal in this case [9]. handling of nonpublic personal information at least once a
The case was settled outside of court in early 2001. year, and give their customers the opportunity to opt-out
information sharing with nonaffiliated third parties. For
Application of trespass theory to other areas of the privacy protection purposes, the Act and its corresponding
Internet environment, such as unwanted email, has implementations define “financial institution” very widely
received similar oppositions because of its pernicious to cover any company that is engaged in financial
effects to the integrity of the global Internet system [10]. activities. For example, a financial software company is
considered to be a “financial institution” for privacy
The trespass theory will probably not be accepted within protection purposes and if the company sells products or
the Internet context. Information aggregation should not services to consumers, it has obligations to disclose its
trigger this as long as it does not abuse the Internet system privacy practices and offer opt-out choices. Clearly,
(e.g., sending repeated unnecessary requests to cause a financial account aggregators are “financial institutions”,
denial of service to web servers). subject to the privacy provisions in GLBA. With this
broad scope, many agencies are involved in the
3.3 Consumer Privacy Protection implementation and enforcement of the Act, these include
the Office of the Comptroller of the Currency (OCC), The
Easy access to information on the Internet has concerned Board of Governors of the Federal Reserve System
people about their online privacy. In the U.S., almost (FRB), the Federal Deposit Insurance Corporation
two-thirds (63.6%) of Internet users and more than three- (FDIC), the Office of Thrift Supervision (OTS), the
quarter (76.1%) of non-users believe that people what go Secretary of the Treasury, the National Credit Union
online put their privacy at risk [11]. When it comes to Administration (NCUA), the Securities and Exchange
financial data, almost all (94%) consumers are concerned Commission (SEC), and the Federal Trade Commission
about privacy and security [6]. For financial account (FTC). These agencies are charged to consult one another
to ensure consistencies of the guidelines across all
4 jurisdictions. Aggregators who are technology
This was decided on Mary 24, 2000. Dramatically, after seeing the
decision on eBay case on May 24, 2000, the court later reworked its companies, such as Yodlee, fall under the jurisdiction of
argument to recognize the potential validity of trespass claim but
remained its initial decision of no injunction because of too little
evidence of harm. See details at “The Rise of the Chief Privacy Officer” by Pamela Mendels,
tickets-2000-03-27.html. BusinessWeek Online, December 14, 2000.
the FTC, which conducts enforcement by reacting to by the Department of Commerce6. Unfortunately,
complaints and does not run routine compliance financial services are excluded from the agreement
examinations as banking regulatory agencies normally do. because they are not regulated by the Department of
However, these companies will be strictly scrutinized Commerce7. In April 2001, the E.U. rejected a U.S.
under vendor management guidelines for traditional request for postponing the approval of a model contract
financial institutions. that financial institutions are asked to sign before sending
data to non-E.U. countries. Without resolving this
The reuse/redisclosure limits in the GLBA regulations difference, it is impossible for a U.S. aggregator to obtain
provide that an aggregator may only use the aggregated financial data of their E.U. customers. Even transfer of
information or disclose it to third parties necessary to E.U. employee information to the U.S. for large U.S.
perform aggregation service [13]. This may pose a based large financial internationals will be difficult.
limitation for possible cross-selling opportunities using
the aggregate information. On the other hand, if a Policies for privacy protection on the Internet are still at
consumer fails to opt out of information sharing, an an early stage. The E.U. Privacy Directive has been
aggregator may be allowed to share aggregated scheduled for review by collecting experiences of
information. Between the limitations and opt-out choices, member countries. Required by the GLBA, similar
the regulations do not clearly state the legality of either studies in the U.S. will be done by early 2002. These
one, leaving the delicate issue to aggregators’ own experiences will be helpful for us to understand the issues
discretion. In order to avoid possible damages to at hand and hopefully to arrive at appropriate level of
reputation and loss of trust, even in the case where a privacy protection that can harmonize international
customer does not opt out for information disclosure, an differences.
aggregator should be very careful not to intrude consumer
privacy. 4. Conclusions
Like database protection, privacy protection has its costs Web aggregation is becoming a valuable service for
and benefits. Without sufficient privacy protection, users increasingly more Internet users worldwide. It collects
will be reluctant to put their privacy at risk and sign up for existing data on the web and turns them into useful
aggregation services. On the other hand, over protection information that lowers search costs and simplifies online
will significantly increase administrative costs and result relationship management. Meanwhile, it introduces some
in high prices for financial products. For example, new risks to consumers, services providers, and other
implementation of Privacy Directive will cost EU stakeholders. As with any new IT capability, aggregation
member states $15-20 billion [14]; U.S. will incur $9-36 will be leveraged to minimize risks and bring more value
billion implementation cost to avoid “data embargo” of to the society.
EU [15]. Section 507 of the GLBA allows states to offer
greater privacy protection, which could take the form of Aggregation services are also raising a number of policy
an “opt-in” approach where consumers have full control issues, primarily concerning the protection of databases
of their personal records. This is the exact approach taken and consumer privacy. Both U.S. and E.U. have reacted
by the E.U. in its Privacy Directive. By today’s U.S. to address these issues by instituting new policies such as
standard, “opt-in” is too strict and it is strongly opposed GLBA privacy provisions and E.U. directives for
by the industries, especially the financial services database and privacy. Differences among stakeholders
industry. The Financial Services Roundtable [16] still exist both domestically and internationally. Although
surveyed 90 large banks, insurance and securities it may take a while to reconcile the differences and
companies to estimate consumer benefits from harmonize the discrepancies, consensus is being built
information sharing among institutions. They estimate toward an agreement of sufficient protection without
that the consumers of the 90 institutions can save $17 jeopardizing the integrity of the Internet. Aggregation
billion and 320 million hours per year. The sources of will continue to thrive while we are achieving a
benefits of information sharing include money saved harmonized policy regime for the information age.
through outsourcing to third parties, relationship pricing
and proactive offers; and time saved though call centers, Acknowledgement
Internet based services, third party services, proactive
offers and pre-filled applications. The study has been supported, in part, by BSCH, Fleet
Bank, Merrill Lynch, MITRE Corporation, Singapore-
Similar to database protection, differences of privacy laws MIT Alliances, and Suruga Bank.
between the U.S. and the E.U. have been causing some
problems. The E.U. will cut off data flow to the U.S.
because they deem that the privacy protection in the U.S. 6
See details at As of July 26, 2001, there
does not meet the minimum requirement of the E.U. are 78 companies, who claim to meet all the privacy requirements, are
Privacy Directive. Some of the differences can be on the Safe Harbor List.
reconciled through the Safe Harbor Agreement negotiated From ZDNet UK news, “EU Rejects US Opposition to Privacy
Directive”, 5/8/2001, by Wendy McAuliffe.
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